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of “$18,000 in tax credits”, and (3) petitioners’ expected
“future tax benefits.” Petitioners attached five typed pages to
their Form 656 explaining their OIC. In the attachment,
petitioners stated that their OIC was reasonable in the light of
their protracted dealings with respondent since 1996 and Mr.
Caple’s and Ashley’s extensive medical ailments and the costs
associated with their care.
On September 22, 2004, respondent rejected petitioners’ OIC
on the grounds that petitioners had failed to substantiate their
hardship and that they had sufficient assets to pay the amount
owed.
On October 27, 2004, respondent issued petitioners a Notice
of Determination Concerning Collection Action(s) Under Section
6320, in which respondent determined the notice of Federal tax
levy for taxable years 1993 and 1994 to be proper and determined
that collection of the tax liabilities for those years should
proceed.
On June 26, 2006, respondent issued another notice of intent
to levy. Petitioners filed a “Petition for Redetermination of a
10(...continued)
for $12,000 an antique Porsche that in 2004, had a fair market
value of $9,000, and that in 2004, they sold for $14,000 a motor
boat that they had owned for several years. Petitioners maintain
that they “refunded” the proceeds from the sale of the boat to
Ashley, because they had previously “borrowed” $14,000 from her
college fund.
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